Privacy Policy

Introduction

In New Life Fertility Clinic Mexico, Fertility Clinic Americas, New Life Global, as well as all the members of the New Life group (hereinafter “New Life”) we are faithful believers that our users and customers are a vital part; that is why the security of your information, integrity and confidentiality is our priority, so we protect it through the use, application and maintenance of high digital, physical, technical and administrative security measures.

As our user and/or client, your personal data will be protected and will be treated confidentially, as well as the personal data you provide us with from third parties, according to the service you have requested.

Applicable Law.

The “Ley Federal de Protección de Datos Personales en Posesión de los Particulares”, the “Reglamento de la Ley Federal de Protección de Datos Personales en Posesión de los Particulares” and the Guidelines of the Privacy Notice (hereinafter, the “Personal Data Legislation”) as well as any other law, regulation, circular, decree applicable to us in New Life regarding the protection and/or treatment of personal data in Mexico.

Privacy Policy Purpose

The purpose of this document is to inform you about the type of personal data we collect, the purposes of the processing of your personal data, the transfers of information that we may carry out and the options you have to exercise your rights of access, rectification, cancellation and/or opposition provided for in the Personal Data Legislation.

Responsible for the Use, Processing and Protection of your Personal Data

New life Fertility Clinic Mexico S.R.L de C.V., (hereinafter “responsible”)

Responsible Address

Av. Nichupté, Lt 20 Mz 02, SM 19, Int. 105, Cp 77505, Cancún, Quintana Roo, México.

Personal Data that May be Collected

In order to comply with the purposes set forth in this Privacy Policy, New Life may require and process your personal data within the following categories: identification data, authentication data, contact and location data; in case you do not agree, you may express your refusal through the procedure applicable to the exercise of ARCO Rights and revocation of consent set forth in this Privacy Policy.

At New Life we may process information from third parties that are provided to us by you. Before providing us with such information, you are required to make this Privacy Policy available to such third parties and to obtain their consent for New Life to process their personal data for the purposes stated herein. Your providing New Life with personal data of a third party implies that you have complied with the above, and you are obligated to indemnify and hold New Life harmless from any claim, complaint or proceeding imposed on New Life.

Processing of your Personal Data Purposes

Users and/or Clients:

a) New Life will process your data for the following primary purposes:

• Identify you as a customer of our services.
• Analyze your profile in order to determine if you are eligible to purchase certain services.
• To contact you through telephone calls, sending communications through e-mails, short messages and other physical and/or electronic means of communication.
• To integrate and/or update files, databases and necessary systems through personal data provided by you directly or obtained from public means, agencies, autonomous agencies or authorities both federal and local or third parties who have legitimate access to your information.
• Processing requests for information, questions, clarifications, suggestions, complaints and follow-up to them. Also, keep a history of their services.
• To make reports, monitoring, predictions and analysis in relation to the use, experience and quality of the services.
• Attend and follow up investigations and reviews of complaints and / or claims related to the detection, prevention and combating of conduct that may contravene the provisions of the applicable regulations and / or the services we offer.
• Generate internal reports and/or reports required in accordance with our internal guidelines and procedures.
• To allow you access to any of the properties in which our offices are located.
• To comply with the obligations derived from the legal relationship with you.
• Comply with regulations, policies, and physical security and civil protection measures, such as video surveillance systems, access to facilities, and restricted areas.
• To comply with obligations established in the applicable regulations and to meet requirements formulated by the competent authorities.
• In order to use the digital services that we make available to you for the provision of our services.
• On the occasion of your intervention in negotiations, contracts, agreements, and/or any other legal document or activity in the performance of your employment and/or representation functions in favor of or on behalf of a client and/or third party.
• To inform you of changes in the services contracted by you by means of telephone calls, sending communications through e-mails, short messages, and other physical and/or electronic means of communication, among others.

In New Life, we will keep, once the contractual relationship with you is terminated, those data that, by regulation, may be required in accordance with the provisions of the law of the matter.

b) New Life will also process your personal data for the following secondary purposes, which are independent from the primary purposes, and are not necessary to provide the service.

• Inform you of the launching of new services or changes in existing services that have not yet been contracted by you, by means of telephone calls, e-mails, short messages and other physical and/or electronic means of communication, among others.
• Generate profiles to identify services that may be of interest to you.
• Perform marketing, advertising and commercial prospecting activities.
• Keep the information you have provided us with the purpose of contacting you in order to follow up on the requests initiated to contract our services in which you have expressed interest.
• Invite you to participate in promotions, campaigns, contests and other activities organized by New Life and in case of winning prizes, benefits, deliver them; inform you or invite you to participate in our non-profit activities of social commitment that aim to promote the development of people.
• Perform statistical analysis to generate information models and/or profiles of current and predictive behavior.

The present purposes are based on your consent, which means that you may at any time oppose or revoke your consent for your Personal Data to be processed for any of the secondary purposes mentioned herein. Likewise, we inform you that in case you grant your consent, the present purposes will subsist even when you do not maintain a legal relationship with New Life.

If you do not agree with the use and processing of your data for the secondary purposes described in this section, you may choose to revoke your consent by following the procedure described in this Privacy Policy.

Client Prospects

At New Life we will process your personal data for the following primary purposes that are necessary to carry out the possible legal relationship between us and you:

• Send information by electronic means related to the contracting process of any services offered by us.
• Contact you by phone to provide guidance on your service remotely or to schedule an appointment.
• To attend to your queries through various means of contact related to your procedure.
• Send you through various means of contact information on the status of your transaction.
• As a prospect, once the process is completed, we will process your personal data in accordance with the purposes described in this Privacy Policy for New Life Clients.

If you do not want New Life to process your personal data for any of the purposes described in this section, you must submit your request following the procedure outlined in the “Exercise of ARCO Rights and Revocation of Consent” section of this Privacy Policy at any branch of New Life, which will channel it to our legal department to be dealt with.

Personal Data Transfers

In New Life we may transfer your personal data without requiring your consent to the following third parties for the following purposes:

1) To the following authorities in order to comply with legal obligations, as well as to comply with the primary purposes informed in this Privacy Notice: Federal, state or municipal public agencies and entities, as well as to the competent authorities and/or third parties in the cases legally provided for.
2) When it is required to transfer your information for the safeguarding of a public interest or for the pursuit of justice.
3) When the transfer is required by virtue of a contract entered into in the interest of the holder, by the responsible party and a third party or is necessary for the provision of medical or healthcare services.
4) When the transfer is provided for in laws or treaties to which Mexico is a party or which are applicable to the Controller.
5) When the transfer is necessary for the recognition, exercise or defense of a right in a judicial process.
6) When the transfer is necessary for the maintenance of the legal relationship between the data controller and the data subject.

Exercise of ARCO Rights and Revocation of Consent

You or your duly accredited representative, when applicable, may exercise the rights of Access, Rectification, Cancellation or Opposition (A.R.C.O.) and Revocation of Consent that the “Ley Federal de Protección de Datos Personales en Posesión de los Particulares” (Federal Law for the Protection of Personal Data in Possession of Individuals) provides for.

In the case of requests for rectification, the modifications to be made must be indicated and the documentation supporting the request must be provided.

The request and the aforementioned documents must be submitted at any New Life branch, which will channel the request to our legal department to be attended. The department will process your request for the exercise of the A.R.C.O. and revocation of consent rights in a term no longer than 20 (twenty) business days from the date of receipt. It is important to mention that the exercise of any of the A.R.C.O. and consent revocation rights is not a prerequisite nor does it prevent the exercise of any other right. If your request is granted, it will be effective within 15 (fifteen) business days following the date on which the response is communicated. The aforementioned deadlines may be extended once for an equal period, if justified by the circumstances. In the event that the information provided by you for these purposes is insufficient or erroneous, or if the necessary documents are not included, we require you, one time only, within a period of 5 (five) business days following the receipt of the request, to specify the missing information or documentation. You will have 10 (ten) business days to comply with such request.

The response to requests for A.R.C.O. rights and Revocation of Consent that fully comply with the aforementioned requirements, will be notified to you or your representative only via email from the address Legal@newlifemexico.net of our legal department; therefore, it is essential that you provide us with an email address for the request to be answered, otherwise, your request will be considered as not submitted, leaving your right to submit a new request.

Additional Choices and Means to Limit the Use or Disclosure of Your Personal Data

If you wish to limit the use or disclosure of your personal data, you may do so through the procedure indicated in this Privacy Notice in the section “Exercise of ARCO Rights and Revocation of Consent”, or by registering in the “Public Registry of Users” (REUS in Spanish) or any other that may be implemented by the Mexican authorities.

Modifications to the Privacy Policy

This Privacy Notice may undergo changes or updates derived from modifications or additions to the Personal Data Legislation, due to our own needs, due to the services or their modifications that we offer, in compliance with our data privacy practices, changes in our business model, material changes in the collection of information, requirements of information transfers to different managers or countries or for other causes. Any modification to this Privacy Notice will be informed through any of the following means: A communication by e-mail or message to your cell phone; through www.newlifemexico.net, or any other electronic means. Also, if required by applicable law, your consent will be obtained again.

Mechanism for the Data Subject to Accept or Not the Transfer of your Data

By not expressing your refusal to this Privacy Policy, you agree to the transfers provided herein, to entities belonging to the same New Life group and/or to business partners and/or to third parties with whom we have entered into legal agreements, for the fulfillment of these and so that they can:

• Contact you and offer you services that may be of interest to you.
• Determine whether you are subject to purchase the services offered by our business partners.
• To integrate databases so that entities belonging to the same New Life group can improve the services offered, as well as for commercial prospecting purposes, facilitate service contracting, risk management and regulatory compliance. In case you would like to express your refusal for us to carry out the transfers indicated in this Privacy Policy, please refer to the process indicated in the section “Exercise of ARCO Rights and Revocation of Consent”.

New Life Mexico Legal Department.